United States v. Fine, No. 19-3485 (8th Cir. 2020)
Annotate this CaseThe Eighth Circuit affirmed defendant's sentence imposed after he pleaded guilty to conspiring to distribute methamphetamine, distributing methamphetamine, conspiring to commit money laundering, and tampering with a government witness. The court held that the district court did not err in denying defendant's motion for a sentence reduction under 18 U.S.C. 3582(c)(1)(A)(i). The court explained that, although defendant's argument relies in part on decisions that were issued after his sentencing, his challenge to the career offender determination was still a challenge to his sentence. Furthermore, a federal inmate generally must challenge a sentence through a 28 U.S.C. 2255 motion, and a post-judgment motion that fits the description of a motion to vacate, set aside, or correct a sentence should be treated as a section 2255 motion. In this case, because defendant did not seek authorization to file a successive motion as required by section 2255(h), the district court correctly determined that defendant's challenge to his career offender determination was an unauthorized successive habeas petition. The court rejected defendant's other asserted ground for a sentence reduction, post-conviction rehabilitation. The court concluded that the district court correctly recognized that rehabilitation of the defendant alone shall not be considered an extraordinary and compelling reason.
Court Description: [Colloton, Author, with Gruender and Grasz, Circuit Judges] Criminal case - Sentencing. The district court did not err in denying defendant's motion for a sentence reduction under 18 U.S.C. Sec. 3582(c)(1)(A)(i); defendant's challenge was a challenge to his sentence, which can only be brought through a Section 2255 motion; as defendant did not seek authorization to file a successive motion as required by 28 U.S.C. Sec. 2255(h), the district court was correct in determining that defendant's challenge to his career offender determination was an unauthorized successive habeas; rehabilitation, alone, is not an extraordinary and compelling reason for a sentencing reduction under 28 U.S.C. Sec. 944(t).
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